ML20216F215
| ML20216F215 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 09/14/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20216F206 | List: |
| References | |
| 70-0925-99-01, NUDOCS 9909210213 | |
| Download: ML20216F215 (15) | |
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ENCLOSURE I
! U. S. NUCLEAR REGULATORY COMMISSION l l REGION IV I
Docket No.: 70-925 License No.: SNM-928 l
Report No.: 70-925/99-01 1
Licensee: Cimarron Corporation Kerr-McGee Center .
Oklahoma City, Oklahoma 73125 l Facility: Cimarron Site Location: Crescent, Oklahoma Dates: July 9 through August 17,1999 Inspector: Louis C. Carson 11, Health Physicist Fuel Cycle & Decommissioning Branch Division of Nuclear Materials Safety Approved By: D. Blair Spitzberg, PhD., Chief Fuel Cycle & Decommissioning Branch Division of Nuclear Materials Safety Attachments: SupplementalInformation Analysis of Cimarron and NRC Soil Sample Data Sets for Agreement i
9909210213 990914 PDR ADOCK 07000925 C PDR m ._
9 EXECUTIVE
SUMMARY
Cimarron Corporation, Cimarron Site NRC Inspection Report 70-925/99-01 Cimarron is conducting site remediation activities in preparation for the termination of License SNM-928. Decommissioning inspections and radiological surveys have been conducted at Cimarron as part of the overall NRC confirmatory survey process. This inspection was a continuation of this process. The licensee is authorized to bury soil contaminated with 3 low-enriched uranium at the Cimarron site, if the soil meets the criteria of the NRC branch technical position (BTP) for soil and the averaging guidance agreed to under the Cimarron letter dated February 25,1997. This inspection involved reviewing final status survey records and collecting soil samples from Sub-Area O, Waste Ponds 1 and 2 to confirm compliance with the ;
license, BTP soil limits, and the averaging guidance. This inspection also included a review of I the site's decommissioning status, manageraent organization and controls, radiation protection program, and environmental monitoring program.
Decommissionina. Closecut Survey. and Site Status
- Site decommissioning activities were conducted in accordance with applicable license conditions and regulatory requirements. Site fences were in good condition, and perimeter postings were appropriate. No health or safety hazards were identified l (Section 1).
- Twelve soil samples werg collected from Sub-Area O during this inspection. The samples were collected from the same locations by both the NRC and the licensee as part of the NRC confirmatory suntey program (Section 1).
- NRC measurements of 12 split soil samples from Sub-Area O showed that when the approved volumetric averaging method is applied, the samples met the concentration guidelines values required to meet BTP Option 1 criteria. No significant bias or statistical errors between the licensee's soil sample results and the NRC's results were identified. Licensee measurement methods and counting times were found to be acceptable. Radiation exposure levels at Sub-Area O were less than 10 pR/hr above background levels (Section 1).
. Radiation exposure rate levels at Sub-Area O were less than 10 pR/hr above background levels (Section 1).
Manaacment Oraanization and Controls 1
- The licensee's management organization in support of decommissioning and radiation protection was in accordance with license requirements. Audits were comprehensive !
and satisfactorily conducted (Section 2).
Radiation Protectios
- The licensee had implemented a radiation protection program that met ALARA goals and was in accordance with license conditions and 10 CFR Part 20. Internal and extemal personnel exposures were well below 10 CFR Part 20 limits (Section 3).
. Survey instruments used during the Sub-Area O release surveys and confirmatory surveys had been calibrated in accordance with procedures and the recommendations of NUREG/CR-5849 and ANSI N 323-1978 (Section 3).
Environmental Protection
. Environmental protection and monitoring had been conducted in accordance with license requirements (Section 4).
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Report Details 1 Decommissioning inspection Procedure for Fuel Cycle Facilities, Closeout inspection and Survey, Site Status (83890/88104) 1.1 Inspection Scope The site status and decommissioning activities were reviewed to determine if activities were being conducted in accordance with the license, regulatory requirements, and the proposed Cimarron Decommissioning Plan. The licensee's proposed Cimarron Decommissioning Plan commits the licensee to follow the recommendations in NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination."
As part of the NRC confirmatory surveys process,12 soil samples from Sub-Area O, Waste Ponds 1 and 2 were collected and split for analysis by the NRC and licensee.
The samples were analyzed for total uranium to determine if the samples met the BTP requirements, NUREG/CR-5849, and the averaging guidance " Method for Surveying I and Averaging Concentration of Thorium in Contaminated Subsurface Wils," for l uranium in soil samples. The sample results were also compared with analytical results obtained by the licensee.of soil samples from the same locations as the NRC samples.
1.2 Observation and Findinas
- a. Site Status Cimarron is in the final stages of site remediation in preparation for termination of its nuclear materials license. The licensee's Decommissioning Plan was submitted to the NRC in April 1995 and is under review. The licensee has continued to implement decommissioning activities in accordance with the Decommissioning Plan, although the l plan has not received NRC approval. However, the licensee's activities have been l l
coordinated with the cegnizant project manager in the Office of Nuclear Materials Safety and Safeguards. The licensee's current activities included soil sampling, radiation surveying, groundwater remediation planning, characterization of radioactive material ;
areas, and facility naaintenance. Remediation at the Cimarron site was more than l 98 percent complete. Sub-Area O, Waste Ponds 1 and 2 final soil remediation efforts had been underway by Cimarron since 1978. Final survey activities for the site were in i progress. This inspection was a continuation of the NRC's confirmatory survey program for the Cimarron site.
- b. Site Tour A site tour was performed to verify that activities were being conducted in accordance with applicable regulations and license conditions to ensure that controls were adequate to protect the health and safety of the workers and the public. During the tour, buildings, fences, gates, construction, and operating equipment were observed. The inspector noted that security was maintained by site security personnel who prevented
unauthorized access to the site. The licensee maintained locked gates at en'rances to site property, and visitors were required to check in at the main office when accessing the site property. The inspector determined that licensed material was secure within the site property as required by 10 CFR 20.1801. Additionally, fences were posted with radioactive material signs as required by 10 CFR 20.1902.
- c. Confirmatory Radiation Soil and Sediment Samolina Twelve soil samples from Sub-Area 0, Waste Ponds 1 and 2 were collected and split for analysis by the NRC and licensee. The samples were analyzed for total uranium to l determine if the samples met approved concentration values. The inspector reviewed l the licensee's procedures for col!ecting and preparing soil and sediment samples and !
observed licensee staff collect, prepare, and split the samples for analysis by the NRC.
The samples were expected to contain urani.a that met the NRC's BTP concentration -
values and be consistent with the licensee's lotter dated February 25,1997. BTP Option 1 specifies an average residual uranium concentration of 30 picocuries/ gram (pCi/g) total uranium. The February 25,1997 letter referenced the guidance " Method for Surveying and Averaging Concentration of Thorium in Contaminated Subsurface Soils,"
for uranium in soil samples. These guidelines allowed several criteria for individual samples of radioactivity in soil to exceed the BTP concentration based on the volume averaging and depth of the material. The maximum guideline value specified for any individual sample was 242 pCi/g.
The NRC split soil samples were sent to the NRC Region lli laboratory for analysis on July 12,1999. After the NRC samples were shipped for analysis, the licensee analyzed the split soil samples for uranium using a Nal soil counter as a quality assurance measure. The licensee counted the samples at 15-minute intervals.
The licensee's July 1999 soil analysis results and data were comparable to the NRC's of
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Sub-Area O results. Licensee results indicated that the samples met the approved criteria specified in the BTP and averaging criteria. NRC sample results were compared with the licensee's results to confirm that uranium levels met the license limits and were ;
consistent with the corresponding licensee measurements. The comparison of the analytical results were discussed with licensee representatives telephonically on August 17,1999.
Nine of the 12 soil sample results were below the 30 pCi/g concentration of BTP Option
- 1. Three of the individual samples exceeded this concentration. Samples collected at location No.10 measured 55.7 pCi/g by the licensee and 74.2 pCL/g by the NRC.
Samples collected at location No.12 measured 82.0 pCi/g by the licensee and 95.4 pCi/g by the NRC. Additionally, the NRC Sample No. 8 result measured 30.2 pCi/g. However, the net residual contamination remaining in this soil samplo, considering natural background and instrument error, met the 30 pCi/g limit for uranium.
The inspector confirmed that the licensee appropriately applied the averaging criteria and the maximum guideline value to the area surrounding Sample Nos. 8,10, and 12.
The inspector determined that the three individual NRC soil sample results which exceeded the BTP concentration value also met the approved averaging criteria. The L
6 results of the NRC confirmatory surveys did not identify any new areas of contamination.
Additionally, the confirmatory survey results supported the licensco's conclusion the soil in Sub-Area O, Waste Ponds 1 and 2 met the approved criteria specified in the BTP and averaging criteria.
The following table shows the results of the confirmatory soil and sediment samples at l and around Sub-Area O. Attachment 2 to this report includes a statistical analysis of the l l licensee and NRC soil sample results baseo on the Wilcoxon Rank Sum test described l in NUREG-1575,
- Multi-Agency Radiation Survey and Site investigation Manual l l
l (MARSSIM)." This test showed the data sets to be in agreement.
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s jConfirmatory Soil asui SeclinieM Sample Results For Sub-Area Oh
! Locaticn Sample Depth Licensee July 99 NRC July 99 (Sample #) feet U (pCi/g) U (pCi/g)
OQmitf4tfB 0-0.5 5.1 1.7 6.2 2.9 375N325E i ElEd2Ml(fff 0-0.5 1.5 0.3 4.8 3.2 37fM285E 4 i
l stM W1 0-0.5 7.6 1.7 6.4 3.6 465N\290E i
lev 4ielsfipl%i 0-0.5 6.1 1.7 5.7 3.9 l 465N\285E l elema50ga!Ei 0-3 25.5 2.0 29.5 3.2 455N\279E l
MMMM 0-1 5.3 1.7 4.5 2.2 1 455N\280E
' t :r h 11.6 1.5
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6-7 15.9 5.5 440N\296E i
MMTeliiM1 6-7 20.0 1.9 30.2 7.5 495N\535E august & W 6-7 12.1 1.7 12.1 2.4 l 545N\520E M 7-8 55.7 1.90 74.2 8.1 545N\580E l 4MV@$ 0-1 2.6 1.3 1.6 0.5 545N\580E M@53%3I69F 7-8 82.0 3.0 95.4 12.4 525N\580E i
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- d. Statistical Comparison and Evaluation of Sample Results Overall, the NRC measurements confirmed that the licensee's Sub-Area O soil split samples met the NRC's acceptance criteria. However, the inspector analyzed the quality of the NRC's and licensee's soil sample results to evaluate if there was statistical agreement between the two sets of data. Using the Wilcoxon Rank Sum i statistical test (Mann-Whitney test) from NUREG-1575, " Multi-Agency Radiation Survey and Site Investigation Manual," the inspector found no significant bias or statistical errors between the licensee's soil sample results. Licensee measurement methods and counting times were determined to be acceptable. Refer to Attachment 2 of this inspection report for the results of the statistical test.
- e. Confirmatorv Exposure Rate Survey Results Sub-Area O exposure rates had been evaluated by the licensee using a portable Nal detector. Background radiation levels around the site averaged 7 microRoentgen ,
(pR/hr). Sub-Area O radiation levels measured by the licensee averaged 8 pR/hr.
Confirmatory e (posure rate surveys were performed by the inspector using a portable i
Nal detector at the Sub-Area O soil sample locations. Site background readings measured by the inspector averaged 8 pR/hr. The inspector's Sub-Area O measurements were 8-12 UR/hr, and no hot-spots were found during the inspector's j survey. The inspector concluded that radiation exposure levels at Sub-Area O were less than 10 pR/hr above background levels.
1.3 Conclusion Site decommissioning activities reviewed during the inspection had been conducted in accordance with the applicable license conditions and regulatory requirements. Site fences were in good condition, and perimeter postigs were appropriate. No health or safety hazards were identified.
NRC measurements of 12 split soil samples from Sub-Area O showed that when the approved volumetric averaging method is applied, the samples met the release criteria.
No significant bias or statistical errors between the licensee's soil sample results and the NRC's results were identified. Licensee measurement methods and counting times were found to be acceptable. Radiation exposure levels at Sub Area O were less than 10 pR/hr above background levels.
2 Management Organization and Controls (88005) 2.1 Inspection Scone The licensee's management organization and QA program were reviewed by the inspector to ensure compliance with license conditions, regulatory requirements, and
, commitments to NUREG/CR-5849. The proposed Cimarron Decommissioning Plan l commits the licensee to the recommendations of NUREG/CR-5849, Subsection 4.1.1
! " Quality Assurance." This inspection assessed the corporate audits conducted pursuant to NUREG/CR-5849 and the license.
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l 2.2 Observations and Findinas 1 a. Manaaement Oraanization l
The Cimarron Radiation Protection Plan describes the corporate and site organization.
l The onsite organization structure had not changed since the last inspection. The l ,
inspector reviewed the licensee's organization and assignment of personnel . .
responsible for implementing the proposed Cimarron Decommissioning Plan. At the
- l. time of this inspection, the licensee's staff consisted of four Cimarron employees, four L
security contractors, and three consultant contractors. The Cimarron staff included a -
! health physicist, a decontamination specialist, contractor engineers, and a Quality -
i' Assurance (QA) manager. The inspector found that the licensee's organization was consistent with the license, NUREG/CR-5849, and the proposed Decommissioning Plan.
- b. Decommissionina Audit During 1998, the licensee's corporate auditors conducted quarterly audits to verify the extent to which Cimarron's decommissioning program was in compliance with NUREG/CR-5849. The inspector reviewed three of the 1998 audits and corrective actions. Program areas audited included the following:
. Radiation Protection Plan implementation
. Procedure KM-CI-RP-38," Survey Requirements and Frequencies
. 10 CFR Part 70 The audits identified findings and made observations for improvement. At the time of this inspection, Cimarron onsite staff had taken corrective actions to prevent recurrence on the findings and observations. Licensee staff had identified the:
underlying causes of most of the findings. The inspector noted that site staff, corporate management, and the As low As is Reasonably Achievable (ALARA)
Committee were continuing to develop corrective actions for the audit findings and observations. The inspector also determined that ALARA Committee continued to meet in accordance with Procedure KM-Cl-RP-11. "ALARA Committee." The inspector found that the licensee's audits and proposed corrective actions were consistent with NUREG/CR-5849, and met the requirements of the license.
u 2.3 Conclusion The licensee's management organization for site decommissioning and radiation protection was found to be in accordance witn license requirements. The licensee's audits were consistent with NUREG/CR 5849 and met the requirements of the license.
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3 Radiation Protection (83822) 3.1 Inspection Scope An inspection of radiation protection and decommissioning activities was performed to determine compliance with regulatory requirements established in the license and 10 CFR Part 20.
3.2 Observations and Findinas The inspector reviewed the licensee's dosimetry records for doses received from July 1998 through July 1999. The licensee had used film badges for external radiation dose determinations. Radiation doses for Cimarron workers for 1998 were generally less than 5 millirem. Workers had no measurable extemal doses detected thus far in 1999. The inspector reviewed the licensee's intemal exposure records. The licensee analyzed breathing zone air lapel samples to determine intemal exposures. For 1998 and 1999 up to the time of the inspection, no activities had been conducted that required airborne radioactivity monitoring, and therefore, no workers were assigned intemal exposures.
The inspector reviewed Procedure KM-CI-RP-10, "ALARA Program" to determine if the licensee continued to maintain an ALARA program when most decommissioning activities were complete. The licensee's ALARA goals for 1998 were less than 100 millirem per individual and a site collective dose of less than 200 millirem. The site collective dose for 1998 was 7 millirem. The inspector determined that the licensee met its ALARA goals. Additionally, the licensee conducted personnel urinalysis (bioassays) on a monthly basis. The licensee's bioassay action level is 3 picoeuries/ liter (pCi/l), and no worker had exceeded the action level since 1995.
The inspector reviewed 1998 exposure records and NRC Form 4s of two former l Cimarron radiation workers for compliance with 10 CFR 19.13 and 10 CFR 20.2106 requirements for occupational dose monitoring notification. The inspector found that the licensee had appropriately written letters to the former employees and provided them with their Cimarron personal exposure histones.
The inspector reviewed the licensee's records for 1999 of routine radiation surveys and other radiation safety program activities. The licensee continued to conduct specific radiation surveys and health physics routines on a monthly, quarterly, semi-annual, and annual basis. Selected records reviewed and found satisfactory included: air ,
sampler calibrations, respirator protection inspections, radiation source inventory, l l
smear surveys, and instrument calibrations The inspector reviewed calibration records of instruments used to conduct final status l
surveys. Instrument calibration and functional check records were reviewed for alpha radiation survey instruments and beta / gamma radiation survey instruments used. The inspector's review of these records revealed that the instruments had been calibrated and functionally checked in accordance with the following licensee procedures:
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- KM-Cl-RP-50,"Ludlum 2220/2221 Alpha Probe 43-68/43-4" l
- KM-CI-RP-57,"Ludlum 2220/2221 Beta Probe 43-68" ;
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- KM-Cl-RP-59, "Eberline PRM-6/N-15 Detector"
- KM-Cl-RP-62,"Cimarron Soil Count #2 Operation" Additionally, the calibrations were consistent with the recommendations of NUREG/CR-5849 and ANSI N 323-1978," Radiation Protection Instrumentation Test and Calibration." ,
The licensee used a Nal detector to conduct soil analysis for uranium. Radiation Protection Procedure KM-CI-RP-62 was used for soil counter operations. This procedure contained instructions for operational checks, calibration checks, cesium-137 energy and efficiency checks, background determinations, and sample counting. Total uranium was determined by using a scaling factor applied to the uranium-235 value.
The alpha and beta / gamma survey instruments used during the Sub-Area O release surveys and confirmatory surveys had been calibrated in accordance with licensee procedures and the recommendations of NUREG/CR-5849 and ANSI N 323-1978.
3.3 Conclusion The licensee had implemented a radiation protection program that had met ALARA goals and was found to be in accordance with license conditions and 10 CFR Part 20.
Intemal and external personnel exposures were well below 10 CFR Part 20 limits.
Survey instruments used during the Sub-Area O release surveys and confirmatory surveys had been calibrated in accordance with procedures and the recommendations of NUREG/CR-5849 and ANSI N 323-1978.
4 Radioactive Waste Management and Environmental Protection (88035/88045) 4.1 Inspection 193gte The inspector reviewed the licensee's environmental protection activities to determine '
compliance with license and regulatory requirements. Areas reviewed included the licensee's gmundwater monitoring program and environmental TLD monitonng l program. l 4.2 Observation and Findinas Groundwater Contamination l
Section 15 of the Cimarron Radiation Protection Plan requires the licensee to implement an environmental monitoring program that includes groundwater monitoring.
The inspector reviewed the licensee's 1998 Environmental Monitoring Report that was <
generated in accordance with Procedure KM-CI-RP-43, " Environmental Monitoring."
Groundwater monitoring results measured technetium-99 contamination between 428 pCi/l and 2640 pCi/l in monitoring wells (MW) 1208,1312,1313, and 1336A during 1998. The inspector noted that the technetium concentrations had decreased 33 to 49 percent since 1997. Additionally, MWs 1313,1315,1316,1317 and 1331 measured uranium contamination between 39 pCi/l and 2354 pCi/l during 1998, which
represented a reduction in uranium contamination 23 to 65 percent since 1997. The inspector noted that the licensee was investigating groundwater contamination and had issued a groundwater corrective action plan to the NRC in March 1999 as part of the Decommissioning Plan that is currently under NRC review. The licensee will continue to collect groundwater samples from the monitoring wells on a quarterly basis until the results indicate over a 2-year period that water meets the uranium groundwater standard of 180 pCi/1. The licensee has estimated that it would take at least 4 years for the groundwater to cleanup by natural attenuation. However, the licensee was continuing to evaluate whether they needed to remove the source of the groundwater contamination by some active means. The inspector determined that the licensee was adequately pursuing resolution of groundwater contamination matters in accordance with Procedure KM-CI-RP-43 and NRC requirements.
Ambient Radiation Section 15 of the Cimarron Radiation Protection Plan requires the licensee to implement an ambient radiation environmental monitoring program. The inspector reviewed the licensee's 1998 environmental TLD monitoring report that was generated in accordance with Procedure KM-CI-RP-43. The licensee has 20 environmental TLD monitoring stations around the site. Environmental TLD Station 14 represented the site's background measurement and was located in the southwest section of the site.
During 1998, TLD Station 14 measured 69 millirem. The highest onsite ambient radiation was located at TLD Station 3 (Uranium Yard) which measured 131 millirem or 62 millirem above background radiation. Based on the inspector's review of the remaining TLD stations onsite and at the site boundary, the inspector determined that potential radiation dose to any member of the public from licensed material would have been well below the 100 millirem per year limit.
4.3 Conclusion Environmental protection and monitoring were found to be conducted in accordance with license requirements.
5 Exit Meeting Summary The inspector presented the inspection results to the licensee representatives at the conclusion of the onsite inspection on July 9,1999, and during telephone conversations on August 17,1999. Licensee representatives acknowledged the findings as presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.
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r 1 ATTACHMENT 1 SUPPLEMENTAL INFORMATION <
PARTIAL LIST OF PERSONS CONTACTED Cimarron Corporation J. Larsen, Site Manager and Vice President, Cimarron K. Morgan, Radiation Safety Officer Contractor Personnel S. Marshall, Nextep Environmental W. Rogers, Technical Consultant -
L Smith, Quality Assurance Manager INSPECDON PROCEDURES USED IP 83822 Radiation Protection IP 83890 Closeout inspection and Survey IP 88005 Management Organization and Controls IP 88104 Decommissioning inspection Procedure for Fuel Cycle Facilities IP 88035 Radioactive Waste Management IP 88045 Environmental Protection ITEMS OPENED. CLOSED AND DISCUSSED Closed None.
Opened-None Discussed None o
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LIST OF ACRONYMS ALARA as low as is reasonably achievable ANSI American National Standards Institute i BTP branch technical position CFR Code of Federal Regulations HPT health physics technician MW monitoring wc!!s pCi/g picocurie / gram pCl/l picocurie / liter PDR public document room QA quality assurance RSO radiation safety officer SNM special nuclear material SWP special work permit TLD thermoluminescent dosimeter
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